| 23-1037 |
Commissioner of Internal Revenue v. Isobel Berry Culp, et vir |
Third Circuit |
2024-03-19 |
Denied |
|
26-usc-6213 internal-revenue-service judicial-review petition-timeliness statutory-interpretation tax-assessment tax-court-jurisdiction tax-deficiency tax-procedure untimely-petition |
1. Whether 26 U.S.C. 6213(a) grants the Tax Court jurisdiction to review an untimely petition for redetermination of a tax deficiency?
2. Even assumi… |
| 23-957 |
David Michael Bishop, et al. v. United States, et al. |
Tenth Circuit |
2024-03-04 |
Denied |
Response Waived |
administrative-investigation civil-rights due-process first-amendment free-speech irs irs-summons judicial-review powell-factors standing tax tax-procedure |
Is the United States Internal Revenue Service1 summons process subject to quashing and constraint by operation of the First Amendment as interpreted t… |
| 23-382 |
Phyllis Carr v. Internal Revenue Service, et al. |
Ninth Circuit |
2023-10-12 |
Denied |
Response Waived |
administrative-procedure irs-audit tax-complaints tax-dispute-resolution tax-procedure tax-refund taxpayer-advocate-service taxpayer-bill-of-rights |
1. Does the closing of an examination/audit following complaints of violation of the Taxpayer Bill of Right against the IRS auditors during the audit … |
| 22-54 |
William A. Goddard v. Commissioner of Internal Revenue |
Ninth Circuit |
2022-07-20 |
Denied |
Response WaivedRelisted (2) |
administrative-law agency-deference irs-regulations kisor-v-wilkie partnership-audits partnership-election regulatory-interpretation tax-interpretation tax-procedure tefra tefra-audit |
Whether a court can give deference to an agency's regulatory interpretation without considering the limitations on agency deference set out in this Co… |
| 20-1583 |
Jeffrey Olson v. Minnesota Commissioner of Revenue |
Minnesota |
2021-05-14 |
Denied |
Response Waived |
administrative-procedure appeal commissioner-order commissioner's-order due-process mail-notice ordinary-mail procedural-due-process tax-appeal tax-assessment tax-procedure |
Under Minnesota tax procedure, the central procedural event is the issuance of a Commissioner's Order, by which the Minnesota Commissioner of Revenue … |
| 20-1014 |
Organic Cannabis Foundation, LLC, dba Organicann Health Center v. Commissioner of Internal Revenue |
Ninth Circuit |
2021-01-28 |
Denied |
|
administrative-law due-process equitable-tolling fifth-amendment judicial-notice jurisdictional-deadline tax-law tax-procedure |
L Is 26 U.S.C. § 6213(a)'s deficiency petition (90-day) Filing Deadline jurisdictional (such that it is not subject to equitable tolling) under curren… |
| 20-558 |
Jon D. Adams v. Commissioner of Internal Revenue |
Fifth Circuit |
2020-10-29 |
Denied |
Response Waived |
26-usc-6404e case-law fifth-circuit interest-abatement judicial-review lee-v-commissioner statutory-interpretation tax-abatement tax-law tax-procedure |
The Appellant (hereinafter referred to as "the Taxpayer") is seeking abatement of interest assessed by the Appellee (hereinafter referred to as "the C… |
| 20-5444 |
Mark Louis Sanders v. United States |
Federal Circuit |
2020-08-21 |
Denied |
Response WaivedIFP |
administrative-law administrative-procedure asset-monetization civil-rights due-process government-overreach jurisdictional-challenge property-rights statutory-interpretation tax-procedure |
Respondent, by their own admissions, monetized Petitioner's assets in the amount of $212,945 without jurisdiction and violated their own policies and … |
| 20-110 |
Jack S. Kannry, et ux. v. Commissioner of Internal Revenue |
Second Circuit |
2020-08-03 |
Denied |
Response WaivedRelisted (2) |
administrative-law disaster-relief disaster-tax-relief federal-tax-procedure irs-discretion irs-regulations stafford-act statutory-interpretation tax-procedure taxpayer-rights |
The question thereby presented is whether the IRS should be free to pick and choose which mandated statutes and regulations to apply, and to avoid oth… |
| 19-536 |
Bocilla Island Seaport, Inc., fka Highpoint Tower Technology, Inc. v. Commissioner of Internal Revenue |
Eleventh Circuit |
2019-10-24 |
Denied |
Response Waived |
basis-adjustment deficiency-determination due-process partner-level partner-level-penalty partner-level-proceeding partnership-basis penalty penalty-imposition reasonable-cause statutory-interpretation tax-court tax-court-jurisdiction tax-procedure united-states-v-woods |
This Tax Court partner-level penalty jurisdiction case raises these four interrelated issues:
1) Should "each partner's outside basis [in his partner… |
| 18-9679 |
Gary Raymond Harvey, et ux. v. United States |
Ninth Circuit |
2019-06-14 |
Denied |
Response WaivedRelisted (2)IFP |
in conflict with Chevron and Section 6325(f)(2) administrative-law administrative-procedure chevron-deference irs-fiduciary-duty irs-lien lien-validity limitation-period statute-of-limitations statutory-interpretation tax-debt tax-lien-reinstatement-validity tax-procedure |
Congress enacted the Release of lien or discharge of property Act, 26 U.S.C.A. § 6325 (f) (2); Public Law 115-281, approved 12/1/18, to inform both th… |
| 18-1270 |
Henry M. Jagos, et ux. v. Commissioner of Internal Revenue |
Sixth Circuit |
2019-04-03 |
Denied |
Response Waived |
administrative-law administrative-procedure circuit-court-split circuit-split civil-procedure due-process eighth-circuit judicial-review jurisdiction notice-of-deficiency sixth-circuit standing tax-appeals tax-court tax-court-jurisdiction tax-procedure |
1. Did the Tax Court lack jurisdiction when it had no facially legitimate notice of deficiency?
2. Did the Sixth Circuit Court Of Appeals properly co… |
| 18-1069 |
Diebold Foundation, Inc., Transferee v. Commissioner of Internal Revenue |
Second Circuit |
2019-02-15 |
Denied |
|
circuit-split commissioner-notice jurisdictional-issue second-circuit statutory-interpretation tax-appeals tax-court-jurisdiction tax-liability tax-notice tax-procedure tax-year taxable-year waiver |
1. Whether the Tax Court lacks jurisdiction to consider and determine a liability for an incorrect taxable year when it does not have jurisdiction ove… |